That’s laughable. Without UL, the product is worthless. Why in the world would anyone build inventory that 1) is not marketable without UL and 2) that could be scrapped if UL mandates changes. Silly to think anyone would build product prior to UL approval.
UL is not a complicated process. UL has locations across the country that certifies and recognizes product. The Santa Clara location is excellent. The shortest path to recognition is use UL cert. components. Follow the spacing, heat dissipation, leakage inductance etc requirements and supply product to UL. They will review the design, test the product etc and provide the green light if all is sound. Field testing could help speed the process. Snpw could put panels on a building and due life testing. Measure the MTBF data - actual is always better than calculated.
It is interesting that the below talks about design? Is it possible that the product was submitted and design mods are required? Just a guess.